Telehealth Policy and Politics Update

Join NARHC’s Advocacy Efforts to Protect and Expand Telehealth for RHCs!

Jeffrey Burke, Deputy Director of Government Affairs, NARHC

04/18/2024

NARHC recently launched a new campaign to help members of the RHC community advocate on the importance of telehealth.

This year is set to be another big one for telehealth, because without Congressional action, the Medicare telehealth flexibilities created at the beginning of the COVID-19 pandemic will expire on December 31, 2024. NARHC’s tool allows you to send a message directly to your Members of Congress encouraging them to prioritize RHC participation in telehealth before current flexibilities expire.

You can find this tool, instructions to use it, and ongoing updates to telehealth policy here. With any questions, please email Sarah.Hohman@narhc.org or Jeffrey.Burke@narhc.org.

Current Telehealth Policy for RHCs:

Medicare telehealth policy shifted dramatically for the healthcare industry in response to the COVID-19 pandemic. RHCs–and more broadly, all Medicare providers–faced a rapidly evolving landscape that resulted in new avenues to treat patients, but also created new hurdles that Congress and the Centers for Medicare & Medicaid Services (CMS) must address.

The current policy in place for RHCs (and Federally Qualified Health Centers) was created as part of the CARES Act in 2020. It created a temporary “special payment rule” to reimburse RHCs a set amount—$96.87 in 2024—whenever the RHC provides any of these services via telehealth. For any of these services, RHCs bill one consolidated code—G2025—and these visits and associated costs must be carved out of the RHC’s cost report.

As RHCs know, the “special payment rule” reimbursement amount is significantly less for telehealth visits as compared to RHC in-person visits. After four years, this hastily established, ‘temporary’ rule has slowly become the status quo, and now risks leaving behind rural providers as telehealth continues to proliferate.

To complicate matters further, in 2022 this issue was fixed for mental health telehealth visits—meaning there is normal billing and coding for these services. While this was a positive development, it further complicated the telehealth landscape for RHCs.

NARHC’s Telehealth Policy Position:

NARHC is advocating for:

  • Permanent coverage of medical telehealth encounters
  • A revision of the RHC payment policy to ensure that RHCs do not experience a disparity in reimbursement when seeing patients via telehealth

Several pieces of legislation have been introduced this Congress that achieve these priorities! NARHC is advocating (and our new campaign helps you do so with us) for Congress to pass legislation that incorporates language included in these bills by the end of this year.

  • The HEALTH Act, H.R.5611
  • CONNECT for Health Act of 2023, S.2016/H.R.4189
  • Save America’s Rural Hospitals Act, H.R.833
  • Telehealth Modernization Act, S.3967/H.R.7623

Recent Congressional Interest in Telehealth:

Telehealth is a very popular issue amongst Members of Congress, with many calling it the “silver lining of the Public Health Emergency.”

Feeling the approaching deadline of these flexibilities expiring, however, Congress has been paying increased attention to telehealth, particularly its use in rural communities. Both the U.S. House Ways and Means Committee and the House Energy and Commerce Subcommittee on Health held telehealth hearings in the last month, each discussing permanent expansion of telehealth flexibilities, payment rates, use of audio-only options, remote patient monitoring and more. NARHC was pleased that several of our RHC champions highlighted the value of telehealth for their rural communities specifically!

Broadly, while telehealth is a priority for Members, they continue to raise concerns about how to pay for its next extension and protect the benefit from fraud and abuse. It is imperative that we keep up our consistent advocacy on Capitol Hill!

Get Involved:

While NARHC remains engaged on these developments and is advocating for permanent coverage of all telehealth services and a revision of the RHC telehealth reimbursement policy, we need your help. Members of Congress are most likely to support change on the issues impacting their constituents directly, meaning they need to hear from you about why this is important.

Recent RHC survey data shows that approximately 75% of RHCs reported using telehealth for medical or behavioral health services and we are fighting for you to retain these flexibilities to best serve your patients.

Please take a moment to support our current momentum and contact your members of Congress using our new website tool, doing so could bring about vital change to your RHC. You can find the new tool HERE.